In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more
In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more
Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
3/7/2024
/ Appraisal ,
Charitable Donations ,
Conservation Easements ,
Fair Market Value ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Court ,
Tax Deductions ,
Tax Fraud ,
Tax Liability ,
Tax Planning
On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more
9/27/2023
/ Acquittals ,
Charitable Donations ,
Conservation Easements ,
Criminal Convictions ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fair Market Value ,
Investment ,
IRS ,
Jury Verdicts ,
Real Estate Market ,
Tax Avoidance ,
Tax Deductions ,
Tax Liability ,
Tax Planning
On August 4, 2023, the IRS published proposed regulations that, if finalized, would identify monetized installment sale transactions as a listed transaction. Sellers, intermediaries and other involved parties would be...more
After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more
4/18/2023
/ Enforcement Actions ,
Federal Taxes ,
High Net-Worth ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
Pass-Through Entities ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Tax Returns
Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more
1/12/2023
/ Charitable Donations ,
Conservation Easements ,
Federal Budget ,
Internal Revenue Code (IRC) ,
IRS ,
Pass-Through Entities ,
Regulatory Reform ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Reform
As the IRS and the Department of Justice continue to focus enforcement efforts on conservation easements, the Supreme Court has been asked to settle a dispute regarding the validity of the “protected in perpetuity”...more
Overview -
Over the past year, several tax law changes have been proposed by the Biden administration and, in September 2021, draft legislative language was circulated, which set forth proposed changes to the Internal...more
12/1/2021
/ Biden Administration ,
Capital Gains Tax ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
GILTI tax ,
High Net-Worth ,
Income Taxes ,
Net Investment Income ,
Pending Legislation ,
SALT ,
Share Buybacks ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Wash Sale Rules
The U.S. Congress has been moving swiftly in recent weeks to address the COVID-19 pandemic. The $8.3 billion Coronavirus Preparedness and Response Supplemental Appropriations Act was signed into law by President Trump on...more
3/23/2020
/ Alternative Minimum Tax ,
Charitable Deductions ,
Coronavirus/COVID-19 ,
Families First Coronavirus Response Act (FFCRA) ,
Family and Medical Leave Act (FMLA) ,
Filing Deadlines ,
Filing Requirements ,
Net Operating Losses ,
Payroll Taxes ,
Relief Measures ,
Retirement Funds ,
Self Employed ,
Sick Leave ,
Tax Credits ,
Tax Liability ,
Tax Returns
On January 29, 2014, the Internal Revenue Service (IRS) proposed Treasury regulations under Section 752 of the Code which would change the way in which both partnership recourse and nonrecourse liabilities are allocated. The...more